In general our programs fall under ANSI N323, but in this case it's what the 
vendor QA program prescribes.  IEC 17025 is an international QA doc for testing 
and cal labs.  I think those provisions would apply to their lab instruments 
and not the GM frisker they may be calibrating for you.  That's lab QA, not 
inst cals like ANSI N323.  In the end it's what the vendor describes in their 
QA program and as long as they give us something that will meet ANSI N323 we 
will be happy.

The application of standards can sometimes be an issue.  You might have a 
vendor that performs multiple services with some that might fall under 10CFR50 
and some lesser services that might fall under a lesser ANSI std.  Before we 
approve vendors, we approve them and their QA program is a part of that 
process.  Once they are an approved vendor, we audit them to their QA program.  
We periodically provide feedback to vendors about their QA programs and how 
they can provide their service in the most efficient manner.

I haven't read their QA program, but we only need ANSI N323  which would not 
require a tamper seal on instruments.

Glen Vickers, CHP
Exelon Corp RP Technical Lead
815-216-2723 (work/cell)

From: Powernet <[email protected]> On Behalf Of Tom Meek via 
Powernet
Sent: Tuesday, April 9, 2019 2:25 PM
To: [email protected]
Cc: Tom Meek <[email protected]>; 'Mark Tursa' <[email protected]>; Jim 
VanLooven <[email protected]>
Subject: [EXTERNAL] [Powernet] RP field instrument tamper seals

I have a question regarding tamper resistant seals for calibration on RP 
meters.  A QA audit made a SFR (supplier finding report) at an instrument 
calibration facility stating vendor should be placing these seals on our RP 
meters.

The cited standard is ANSI Z540:1994 Section 11.5, but after some discussion we 
agreed that this only applies to lab standards.  He also cited ISO 17025:2017 
Section 6.4.12 which states "the laboratory shall take practical measures to 
prevent unintended adjustments of equipment from invalidating results."  The 
auditor said that industry interprets this as requiring tamper seals, but also 
said that complying with the ISO standard was a matter of lab certification 
only (not a regulatory requirement).

Does any site require tamper resistant seals on RP field instruments?  Yes    No

If yes how do you handle routine battery and/or desiccant replacement?

What do you do if a seal is found broken or missing.  In short, would the event 
be entered into the corrective action system?

Do you rely on your source check and zero check of the instrument to "validate" 
its calibration in lieu of the tamper seal?

Thanks in advance
Tom Meek, CHP

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